Section 148 permits the Government to notify classes of registered persons and prescribe special procedures for registration, returns, payment and administration. Notification No. 22/2024-Central Tax prescribes a six-month period for seeking rectification to claim the benefit of retrospective Section 16(5). The central issue is whether that limitation validly reflects the safeguards inherent in Section 148, particularly where no mechanism extends the period in extraordinary circumstances. The power to prescribe a special procedure was provisionally recognised, while the validity of the six-month limitation remains for further consideration.

Denial of a requested personal hearing in adjudication violates the principles of natural justice and renders the resulting order unsustainable. The adjudicating authority must independently consider the reply to the show-cause notice and give reasons for accepting or rejecting the explanation; treating the reply as a mere formality is impermissible. The adjudication order was set aside, and the assessee became entitled to fresh adjudication on merits after a reasonable opportunity of hearing.

GST registration cancellation requires strict compliance with Form GST REG-17 and Rules 22(1) and 25. A show-cause notice must state the grounds, allow a reply and specify the date and time for personal hearing; omission of hearing particulars breaches the prescribed procedure and natural justice. Physical-verification reports, supporting documents and photographs must also be uploaded in Form GST REG-30 within the stipulated period before cancellation. Availability of registration-revocation proceedings does not preclude writ jurisdiction where these procedural safeguards are violated. Non-compliance invalidates the cancellation notice and consequential registration-cancellation order.

Passport renewal for an accused on bail under the Central Goods and Services Tax Act should not be restricted below the regular ten-year term without a plausible justification, substantive harm, or reasonable apprehension of absconding. Continuing conditions requiring prior court permission for foreign travel and monitoring safeguards apply regardless of passport validity. Family ties, residence, business, and immovable property in India materially reduce absconding risk. Renewal was therefore directed for the regular ten-year period, subject to all existing conditions governing foreign travel and passport use.

Transitional SGST credit may support a refund claim only where it is carried forward through the prescribed TRAN-1 declaration and demonstrably credited as opening balance in the Electronic Credit Ledger on 1 July 2017. Without the declaration or satisfactory proof of ledger credit, refund of unutilised transitional credit is unavailable. Statutory appellate and revisional remedies must be pursued within prescribed limitation; Article 226 ordinarily cannot revive a time-barred challenge to an assessment order or bypass the legislative scheme of finality. The assessment denying the refund therefore remains undisturbed.

Adjudicatory and quasi-judicial authorities must independently verify all AI-generated legal material against primary sources, cite only accurate and relevant precedents, consider taxpayer authorities, and apply their own mind. Artificial intelligence may assist legal research but cannot replace authentic verification or reasoned decision-making; the issuing officer remains responsible for legal correctness. Reliance on non-existent or irrelevant AI-generated authorities renders the decision-making process defective and may breach applicable departmental instructions. The show-cause notice, cancellation, revocation-rejection and appellate orders were quashed for fresh proceedings, requiring a new notice, consideration of the taxpayer's reply and defence, and a reasoned determination according to law.

Anticipatory bail in alleged fake GST registration fraud may be refused where investigation yields technical links between GST filing credentials and the accused, alongside allegations of creating fictitious entities and receiving client payments. Non-cooperation with the investigation, the need for further technical inquiry, and the justification for custodial interrogation weigh against pre-arrest protection. Alleged misuse of PAN cards and personal credentials, wider economic repercussions, and involvement in other financial-fraud matters further support refusal of anticipatory bail.

Use of AI-generated legal material in quasi-judicial orders requires independent verification, human oversight, and the issuing officer's own application of mind. Reliance on non-existent or irrelevant AI-generated precedents prompted an unconditional apology, and non-compliance with departmental safeguards was directed to be treated as contempt of court. GST registration cancellation proceedings were quashed because the authorities proposed to revise the challenged orders and issue a fresh notice. Fresh adjudication must consider the taxpayer's reply and defence and result in a reasoned order in accordance with law; the merits remain open.

Transitional SGST input tax credit refund requires proof that the unutilised erstwhile-regime credit stood as an opening balance in the Electronic Credit Ledger on 1 July 2017. In the absence of the prescribed TRAN-1 declaration or other satisfactory evidence of that balance, the refund claim fails. Writ jurisdiction under Article 226 ordinarily cannot be used to revive a statutory challenge after the taxpayer's own default has allowed the appeal limitation to expire, particularly where the delay is inordinate. The writ petition was dismissed because the transitional credit was unsubstantiated and the statutory appellate remedy had become time-barred.

Passport renewal may be granted for its regular ten-year term during pending criminal proceedings where prior court permission remains mandatory for foreign travel. Travel restrictions, reinforced by directions to investigating and immigration authorities, provide sufficient safeguards against unauthorised departure regardless of the passport's validity period. In the absence of plausible reasons, substantive harm, or reasonable apprehension, limiting renewal to three years was not justified, particularly given the accused's stated roots in India. Renewal for ten years operates subject to all continuing conditions requiring prior court approval before travel abroad.

GST registration cancellation proceedings require a show-cause notice in Form GST REG-17 that allows seven working days for a reply and specifies the date and time of personal hearing. Omission of hearing particulars breaches the prescribed form and principles of natural justice. Where cancellation is based on physical verification, Rule 25 requires the verification report, supporting documents and photographs to be uploaded in Form GST REG-30 on the common portal within fifteen working days; non-upload invalidates proceedings founded on that verification. Writ jurisdiction remains available despite an alternative revocation remedy where natural justice is violated or the action is ultra vires. Fresh proceedings may be initiated only in compliance with these requirements.

Section 148 permits the Government, on the Council's recommendations and subject to conditions and safeguards, to notify classes of registered persons and special procedures for registration, returns, tax payment and administration. Notification No. 22/2024-Central Tax, prescribing a procedure to implement retrospective input tax credit entitlement under Section 16(5), therefore falls within that power. The validity of the stipulated six-month period for rectification, particularly whether it contains adequate safeguards despite no extension mechanism for extraordinary circumstances, remains under consideration. The writ petitions were kept pending on that limited issue.

Service of a show cause notice solely by uploading it to the common portal was treated as ineffective where there was no acknowledgement of receipt or response from the assessee. An ex parte adjudication under Section 73 of the CGST Act founded on such notice could not be sustained because the assessee lacked an effective opportunity to reply. The ex parte order was set aside, with liberty to submit a response to the show cause notice. The competent authority must then conduct fresh adjudication and pass an order in accordance with law.

Withholding an electronic cash ledger refund during the Revenue's pending appeal requires a specific determination by the Commissioner under Section 54(11) of the CGST Act. Payment or withholding cannot be decided without initiating the statutory process, issuing a show cause notice, and providing the claimant a proper opportunity of hearing. The Commissioner must then pass a reasoned order determining whether the claimed refund should be paid or withheld while the appeal remains pending.

GST appeals must be filed within three months of communication of the order. The appellate authority may admit a delayed appeal only on sufficient cause and only during the further one-month period expressly permitted by the statute. The Limitation Act does not apply to enlarge this limited condonation power where the GST appellate scheme does not provide for such application. An appeal filed after both periods, particularly where the substantial delay remains inadequately explained, is time-barred and cannot be entertained.

GST appeal limitation does not begin merely because an order-in-original is uploaded on the common portal without valid communication to the assessee in the stated circumstances. Although the Appellate Authority remains bound by the statutory limitation under the RGST/CGST Act, delay may be condoned where the assessee could not file the appeal for reasons beyond its control and refusal of merits review would cause grave prejudice. The time-bar dismissal was set aside and the statutory appeal restored for merits determination, subject to the directed deposit of outstanding tax.

Collateral challenge to a CGST adjudication order through an interlocutory application in a pending writ petition was not maintainable because the earlier AGST notice challenge had no connection with the subsequent CGST proceedings. No interim restraint covered the adjudication, and no jurisdictional error by the Proper Officer was established; the writ challenge became infructuous and the interlocutory challenge was misconceived. Bona fide and diligent pursuit of the wrong writ remedy justified allowing recourse to the statutory appellate remedy despite expiry of limitation. Petitioners received liberty to file an appeal under the CGST Act within 30 days, to be considered on merits without limitation objection; prior interim protection was vacated.

GST show cause notices served only through the portal after cancellation of registration do not constitute effective service where the taxpayer cannot access the portal. Adjudication based on such service is liable to be set aside, with the tax authorities permitted to restart proceedings from the show cause notice stage in accordance with law. In fresh proceedings, a personal hearing must be provided where the taxpayer requests it under the statutory requirement. The discussion relies on decisions treating portal-only communication after cancellation as inconsistent with effective notice and procedural fairness.

Rule 96(10) of the CGST Rules restricted IGST refunds on exports in specified circumstances. The High Court's earlier ruling in M/s Hikal Limited treated the rule as ultra vires section 16 of the IGST Act and manifestly arbitrary. Its subsequent omission without a saving clause meant that proceedings based exclusively on an alleged breach of Rule 96(10) could not continue. Accordingly, a show cause notice seeking to deny or recover an IGST export refund under that rule, along with consequential proceedings, was quashed.

Duplicate GST adjudication on the same issues and assessment period is unsustainable where Central GST authorities have already issued an order and that order remains under appeal. The subsequent State GST assessment and rectification orders addressed identical issues for the identical period, thereby duplicating the earlier Central GST adjudication. The State GST orders were quashed, and the writ petition was allowed.